Just past the halfway point of 2024, it's already been a busy year for those following regulatory developments related to per- and polyfluoroalkyl substances (PFAS). Building on its plans in the 2021 PFAS Strategic Road Map...more
EPA recently published a 2024 update to its Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) and Materials Containing PFAS (Interim Guidance), as required by the...more
In furtherance of the U.S. Environmental Protection Agency’s PFAS Strategic Roadmap, which our firm has written about frequently, the EPA released an updated guide on destroying and disposing of PFAS....more
The U.S. Environmental Protection Agency (EPA) announced on April 9, 2024, the release of an updated “Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl Substances and Materials Containing...more
On April 8, the US Environmental Protection Agency (EPA) issued interim guidance for public comment regarding the destruction and disposal of per- and polyfluoroalkyl substances (PFAS). Below, we discuss the guidance and...more
Perfluoroalkyl and polyfluoroalkyl substances (PFAS), commonly known as “forever chemicals,” are a varied group of thousands of manufactured chemicals and have been used in industry and consumer products since the 1940s. In...more
The U.S. Environmental Protection Agency (EPA) issued a proposed rule on Sept. 6, 2022, to designate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS), along with their structural isomers, as hazardous...more
The clock is winding down on businesses interested in commenting on EPA’s proposal to designate nine per- and polyfluoroalkyl substances (PFAS) as hazardous constituents under the Resource Conservation and Recover Act (RCRA)....more
The Minnesota Pollution Control Agency (MPCA) announced on March 26, 2024, that it has published new information concerning per- and polyfluoroalkyl substances (PFAS) in products. This information includes...more
On February 8, 2024, the Environmental Protection Agency (EPA) published two proposed rules that would expand its regulatory authority over PFAS: one to list nine PFAS as hazardous constituents subject to the Resource...more
In February 2018, Ohio become the first state to sue DuPont alleging that the company had released perfluorooctanoic acid (PFOA) into the environment. Since then, multiple state attorneys general (AG) have continued to weigh...more
On February 8, 2024, EPA published a proposed rule to list nine PFAS, their salts and their structural isomers, as hazardous constituents under RCRA regulations. If the proposed rule is finalized, the nine PFAS (PFOA, PFOS,...more
The proposed rules would expand the RCRA Corrective Action regime to PFAS and potentially other emerging contaminants. They may complicate ongoing compliance efforts as well as lead to significant value chain impacts....more
U.S. Environmental Protection Agency (EPA) Administrator Michael Regan signed two proposed rules related to per- and polyfluoroalkyl substances (PFAS) and the agency’s corrective action authority under the Resource...more
On January 31, the US Environmental Protection Agency (EPA) issued two proposed rules to facilitate the targeting of PFAS. The first proposed rule would add certain per- and polyfluoroalkyl substances (PFAS) compounds to...more
Regulatory activity and litigation concerning per- and polyfluoroalkyl substances (“PFAS”) continued to pick up steam in 2023, and 2024 promises to continue this trend and present companies with new PFAS-related challenges....more
The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents ...more
On February 8, 2024, the Environmental Protection Agency ("EPA") proposed two regulations that would add nine per- and polyfluoroalkyl substances ("PFAS") to the list of Resource Conservation and Recovery Act ("RCRA")...more
On February 8, 2024, the U.S. Environmental Protection Agency (EPA) published two proposed rules in the Federal Register that would expand the EPA’s authority to address certain per-and polyfluoroalkyl substances (PFAS) under...more
On February 8, 2024, the U.S. Environmental Protection Agency (EPA) proposed two rules to expand the Agency’s authority to address releases of per- and polyfluoroalkyl substances (PFAS) and other emerging contaminants at...more
The US Environmental Protection Agency (EPA) published on February 8, 2024 two proposed rules addressing per- and polyfluoroalkyl substances (PFAS) under the Resource Conservation and Recovery Act (RCRA). The rules, if...more
The U.S. Environmental Protection Agency (EPA) has taken its first major action of 2024 to regulate per- and polyfluoroalkyl substances (PFAS) across environmental media. On January 31, 2024, EPA issued pre-publication...more
While I was on vacation last week, EPA proposed to identify as “hazardous constituents” nine of the “forever chemicals" known collectively as PFAS. EPA's proposal will now be subject to public comment before perhaps being...more
Last week, the U.S. Environmental Protection Agency (EPA) issued two new proposed rules, which further expand EPA’s regulatory oversight of per- and polyfluoroalkyl substances (PFAS). The first rule would modify the...more
On January 31, 2024, the Environmental Protection Agency ("EPA") proposed two new rules that would add nine per- and polyfluoroalkyl compounds (known as "PFAS") to its list of hazardous constituents regulated under the...more